Antogiovanni v. America's Homes & Communities Real Estate, LLC, 130 Conn. App. 286

Plaintiff sues for fiduciary breach, fraud, interference with business opportunity, contract, good faith and fair dealing, and CUTPA related to a real property purchase.
Property was ultimately purchased by Kate Porch, who was Parker's fiancée and had a business relationship with him.
Trial court found plaintiff proved the asserted causes of action but limited damages, awarding nominal and punitive damages and $24,571.15 in attorney's fees plus $3576.47 interest on fees.
The court relied on an affidavit and a detailed billing statement from plaintiff's attorney, Dowley, submitted with posttrial materials.
Parker objected to Dowley's fee submission; on appeal, the issue centers on whether the court properly relied on those materials.
Connecticut Supreme Court precedent (Smith v. Snyder) governs when a party must present a statement of fees at trial or damages hearing and discusses acquiescence standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the fee award was proper based on Dowley's affidavit and billing statement.	Dowley's detailed fees supported the award under CUTPA.	The court improperly relied on posttrial materials not subject to challenge.	Yes; affirmed the fee award.
Whether the defendant's acquiescence bars challenge to the attorney's fees.	Defendant acquiesced by not objecting to the fee submission.	Acquiescence cannot validate improper fee submission.	Acquiescence bar; court upheld the fee award.

Smith v. Snyder, 267 Conn. 456 (Conn. 2004) (proponent must present fees at trial or damages hearing; acquiescence may sustain fee award)